Court of Appeal of Tanzania

This is the highest level in the justice delivery system in Tanzania. The Court of Appeal draws its mandate from Article 117(1) of the Constitution of the United Republic of Tanzania. The Court hears appeals  on both point of law and facts for cases originating from the High Court of Tanzania and Magistrates with extended jurisdiction in exercise of their original jurisdiction or appellate and revisional jurisdiction over matters originating in the District Land and Housing Tribunals, District Courts and Courts of Resident Magistrate. The Court also hears similar appeals  from quasi judicial bodies of status equivalent to that of the High Court. It  further hears appeals  on point of law against the decision of the High Court in  matters originating from Primary Courts. The Court of Appeal also exercises jurisdiction on appeals originating from the High Court of Zanzibar except for constitutional issues arising from the interpretation of the Constitution of Zanzibar and matters arising from the Kadhi Court.

Physical address
26 Kivukoni Road Building P.O. Box 9004, Dar Es Salaam, Tanzania.
58 judgments

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58 judgments
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Judgment date
December 2021
Appeal dismissed: identification, recent possession and voluntary confessions upheld as proving robbery beyond reasonable doubt.
Criminal law – gang armed robbery – identification evidence – concurrent findings – doctrine of recent possession – admissibility and voluntariness of cautioned statements – chain of custody – competence to raise new grounds on second appeal.
8 December 2021
Defective summing up to assessors and extraneous matters in judgment vitiated the murder convictions; appellants released.
Criminal procedure – summing up to assessors (s.265, s.298 CPA) – duty to explain vital legal/factual points; Identification – requirements and risk of mistaken identity; Judgment – reliance on extraneous matters vitiates conviction; Remedy – nullification, quashment and release vs retrial.
3 December 2021
Failure to address assessors on alibi nullified trial; weak identification and evidential gaps led to quashed conviction and no retrial.
Criminal procedure – Assessors – duty to address on vital points including alibi; omission renders trial nullity; Visual identification – reliability at night, recognition vs naming at earliest opportunity; Delay in arrest and contradictions – raising reasonable doubt; Proof of death – medical evidence not always necessary but absence may create doubt; Retrial – ordered only if in interest of justice (Fatehali Manji).
3 December 2021
Convictions quashed where visual identification was unreliable, the cautioned statement was improperly handled, and possession was unproven.
Criminal law – visual identification – Waziri Amani guidelines; dock identification vs identification parade; cautioned statement admitted but not read aloud – expungement; doctrine of recent possession and requirement of actual possession; failure to call foreign witnesses – adverse inference; burden of proof beyond reasonable doubt.
3 December 2021
Filing a fresh identical application while appealing the order that struck out the original is forum shopping; correct remedy is striking out, not dismissal.
* Civil procedure – Abuse of court process and forum shopping – Filing fresh proceedings while appealing earlier ruling – propriety and remedy. * Civil procedure – Jurisdiction and functus officio – Whether a court can entertain a subsequent application after a notice of appeal is lodged. * Civil procedure – Nullity, dismissal and striking out – Appropriate remedy where an application is found to be unprocedural or a nullity (strike out under section 95).
2 December 2021
Whether time to obtain appeal records should be excluded under s.379(1)(b) CPA is a factual issue requiring documentary proof.
Criminal procedure – computation of time for filing DPP appeals under s.379(1)(b) CPA – exclusion of time to obtain copies of proceedings is a factual matter requiring proof; preliminary objections based on limitation demand documentary evidence; s.59(1)(d) Evidence Act not applicable to taking judicial notice of documents in other proceedings.
1 December 2021
Illegal warrantless search and unread seizure certificate led to acquittal for unlawful ammunition possession.
Criminal law – unlawful possession of ammunition; admissibility of seizure certificate – must be read aloud after admission; searches – warrant required unless emergency; evidence obtained in illegal search expunged; doctrine of recent possession applicable only where property is recently stolen and identified; jurisdiction under Economic and Organized Crime Control Act – consent valid if referent to charged provisions.
1 December 2021
September 2021
Credible unsworn testimony of a child can sustain a sexual‑abuse conviction; birth certificate and medical report are not indispensable.
Criminal law – Child witness evidence – s.127(2) Evidence Act: no mandatory voire dire; child may give unsworn evidence after promising to tell the truth – Proof of age: birth certificate not sole evidence – Sexual offences: medical report not essential; victim’s and eyewitness’ credible testimony may suffice (s.127(6)) – Delay in reporting explained by threats does not destroy credibility.
27 September 2021
The appellant lacked standing to sue on a loan agreement he was not party to, despite providing security.
Contract law – Privity of contract – Locus standi in contractual disputes – Role of guarantors in loan agreements
27 September 2021
Denial of co-accused participation in trial-within-trial and inadequate summing-up to assessors vitiated the trial; retrial ordered.
* Criminal procedure – Trial-within-a-trial – Right of co-accused to participate and to cross-examine when implicated by another's extra-judicial statement – natural justice and fair trial. * Criminal procedure – Assessors – Mandatory summing-up on vital legal issues including admissibility of statements, doctrine of recent possession and circumstantial evidence. * Remedy – Proceedings vitiated by procedural breaches; retrial ordered in the interest of justice.
27 September 2021
Procedural failure to serve formal charge made dismissal unfair; unpleaded/double-payment awards were set aside.
* Employment law – termination – section 37(2) ELRA – employer's burden to prove valid reason and fair procedure. * Disciplinary procedure – Rule 13(2) Code of Good Conduct – requirement to serve formal charge/ summons to show cause. * Remedies – section 40(1) ELRA – permissible awards for unfair termination. * Civil procedure/pleadings – Form No.1 (pleadings) – reliefs must be pleaded; awards beyond pleadings or causing double recovery liable to be set aside.
27 September 2021
Applicant failed to show good cause for extension of time to serve appeal documents; application dismissed with costs.
Civil procedure – Extension of time under Rule 10 – Requirements of good or sufficient cause; adequacy and particularity of affidavit evidence; duty of diligence by counsel; missing annexures and unnamed court officers undermine credibility; service out of time does not cure lack of good cause.
27 September 2021
Failure to serve the application for copies prevented time exclusion under Rule 90, rendering the appeal time-barred and struck out.
* Civil procedure – Appeal time limits – Rule 90(1) and (3) Court of Appeal Rules – written application for copies must be served on respondent to exclude time. * Civil procedure – Supplementary record – Rule 96(7) cannot cure lack of service or jurisdictional time-bar. * Appellate jurisdiction – Section 3A AJA (overriding objective) cannot validate an out-of-time appeal that deprives the Court of jurisdiction. * Appeal struck out for being time-barred.
27 September 2021
Statutory rape conviction upheld where appellant admitted intercourse with a 15‑year‑old; consent immaterial under s130(2)(e).
Criminal law – Statutory rape under section 130(2)(e) – capacity to consent; victim under 18; consent immaterial; best evidence is victim’s testimony; failure to cross‑examine implies acceptance; corroboration not always required in sexual offences.
27 September 2021
Failure to serve the notice of appeal and required copy-application rendered the appeal incompetent and time-barred.
Civil procedure – Appeal competence – Rule 84(1) service of notice of appeal; Rule 90(1) and (3) – time limits and service of application for certified copies; Rule 96(7) inapplicable where documents in record were not served; appeal struck out for incompetence and time-barred.
24 September 2021
Child witnesses may be sworn under s198 CPA; PF3 not read in court must be expunged, yet conviction upheld on remaining evidence.
Criminal law – rape – proof of penetration and identification; evidence of tender‑age witnesses – oath vs promise under s127(2) Evidence Act and s198 CPA; failure to read PF3 – expunging exhibit; appellate jurisdiction on new grounds of appeal.
24 September 2021
Appeal allowed: life sentence for manslaughter reduced to 20 years for failure to consider mitigating factors.
Criminal law – Manslaughter; sentencing principles – manifestly excessive sentence; appellate interference; mitigation: guilty plea, remorse, first offender, time in custody; need to balance aggravating and mitigating factors.
24 September 2021
Recent-possession presumption upheld; charge and trial procedure valid; appeal dismissed and convictions affirmed.
* Criminal law – armed robbery – doctrine of recent possession – unexplained possession of recently stolen property as presumptive evidence. * Criminal procedure – prima facie ruling – compliance with section 231(1) CPA. * Evidence – identification parade unnecessary where victim did not identify assailants. * Statutory interpretation – references to statutes include subsequent amendments (section 12 ILA). * Appellate procedure – second appeals cannot raise new factual matters not determined by first appellate court.
24 September 2021
Minor inconsistencies in dates did not undermine the prosecution; conviction for child rape upheld.
Criminal law – Rape of a child – Evaluation of contradictions between witness testimony and exhibits; requirement to read and record charge and plea; appellate review when lower court omits express evaluation of defence; sufficiency of evidence to prove identity and guilt beyond reasonable doubt.
24 September 2021
Conviction quashed due to defective identification despite medical proof of child rape and explained reporting delay.
Criminal law – Rape of a child – proof by complainant’s evidence and medical report (PF3); delay in reporting – threats and caregiver’s hospitalization as plausible explanation; identification of a stranger – necessity of prior description before arrest or identification parade; defective identification – miscarriage of justice and quashing of conviction.
22 September 2021
Summing up omissions on circumstantial evidence, malice, admissions and alibi rendered the trial a nullity; retrial ordered.
Criminal procedure – Trial with assessors – Duty of trial judge to sum up adequately on vital points of law and fact – Circumstantial evidence: nature and cogency – Ingredients of murder (malice aforethought) – Legal character of oral admissions/confessions – Defence of alibi – Omission to direct assessors renders trial a nullity; retrial ordered.
22 September 2021
Victim’s direct testimony and medical corroboration sustained rape conviction; appeal dismissed.
* Criminal law – Rape – Proof of penetration and identity; victim’s direct testimony corroborated by medical evidence; adverse inference from failure to cross-examine; limits on second appeals for factual matters; no obligation for appellate court to cite statutory provision.
21 September 2021
Defective charge (omitting sentencing provision) and evidential doubts led to quashing of conviction and release of the appellant.
Criminal procedure – charge particulars – omission to state victim's age and sentencing/punishment provision (s.154(2)) – prejudice to accused – requirement to amend charge under s.234 CPA; Evidence – sexual offences – victim's evidence and medical examination – credibility and corroboration; Failure to call material witness – adverse inference; Revisional jurisdiction – nullification of defective proceedings.
21 September 2021
The appellant’s conviction upheld; child victim’s uncorroborated testimony valid under s.127(6) of the Evidence Act.
* Evidence Act s.127(6) – sexual offences – uncorroborated evidence of a child of tender years may sustain conviction where court records reasons and is satisfied of truthfulness. * Admissibility – medical report admitted but not read out; improperly admitted exhibit expunged where oral testimony covered contents and no prejudice shown. * Corroboration – not mandatory in sexual offence cases involving child victims. * Appellate review – conviction upheld where victim credible and prosecution proved case beyond reasonable doubt.
21 September 2021
Child’s promise to tell truth and medical PF.3 sufficed for conviction in sexual offence against a four-year-old; appeal dismissed.
Evidence Act s.127 – child of tender years may testify after promising to tell the truth; s.127(6) permits conviction on child victim’s evidence alone in sexual offences if credibility assessed and reasons recorded; medical PF.3 as corroboration; non-calling of non-essential witnesses not fatal; appellate review confined to law in second appeals.
21 September 2021
Emergency search lawful, but defective identification and improperly admitted confessions led to quashing convictions.
* Criminal procedure – emergency warrantless entry and search – section 42(1)(b)(i)&(ii) CPA – necessity and reasonable grounds for immediate search. * Evidence – caution statements – repudiation by accused – requirement of trial-within-a-trial to determine voluntariness; failure renders statements inadmissible. * Evidence – expert identification – positive identification required to prove items are government trophies; mere appearance/guess insufficient. * Evidence – documentary exhibits – must be read over to and explained to accused; failure may amount to prejudice and justify expunging. * Appellate jurisdiction – Court will not entertain new factual grounds not raised in lower courts.
21 September 2021
Failure to record victim's evidence in first‑person narrative and to note interpreter use rendered the trial null; retrial ordered.
* Criminal procedure – Recording of witness evidence – Section 210(1)(b) CPA – Evidence must be recorded in first‑person narrative not reported speech. * Use of interpreter – Court must record why interpreter used and the languages involved. * Irregularity – Failure to comply with s.210(1)(b) is a fatal irregularity warranting retrial. * Appellate relief – Quashing of conviction and set aside of both trial and appellate judgments; retrial ordered.
20 September 2021
Convictions quashed where armed robbery elements were unproven and recent-possession identification was inadequate.
Criminal law — Armed robbery (s.287A Penal Code) — essential element: use or threat of force must be specifically alleged and proved; Evidence — section 34B statements must comply with procedural safeguards and be read out in court; Recent possession — requires positive identification of property and proof beyond reasonable doubt; Section 231 CPA — duty to inform accused of right to defence after prima facie case; Conspiracy — cannot stand where substantive offence is proven or is unproven making indictment superfluous.
20 September 2021
Child's evidence improperly recorded; identification and age unproven, conviction quashed and proceedings nullified.
Evidence Act s.127(2) – child witness must promise to tell the truth; improper use of voir dire; admissibility and proof of PF3; visual identification on moonlight unreliable; proof of victim's age essential in statutory rape; AJA s.4(2) – nullification and quashing; retrial discretion where prosecution case is materially deficient.
20 September 2021
Armed robbery conviction quashed for defective particulars, improperly admitted confession, weak identification, and failure to consider defence.
Criminal law – Armed robbery – Particulars of offence must state the person against whom actual violence or threat was directed (section 132 CPA) – Defective particulars incurable. Evidence – Cautioned statement – Objection to voluntariness requires court inquiry before admission; failure is fatal and statement must be expunged. Identification – Ability to name suspect at earliest opportunity essential; unexplained delay in arrest undermines reliability. Criminal procedure – Appellate review; appellate court will not entertain new grounds not raised below except on points of law. Duty – Trial court must consider defence evidence.
20 September 2021
Second appeal dismissed — concurrent findings that appellant possessed elephant tusks affirmed; new grounds not entertained.
Criminal law — Unlawful possession of government trophy — Proof of possession by knowledge and control — Admissibility and expungement of documentary exhibits — Limits on raising new grounds on second appeal — Deference to concurrent findings of fact.
20 September 2021
Failure to read admitted documentary exhibits to accused vitiated conviction for unlawful possession of government trophies.
Criminal law – Wildlife trophies – Admission of documentary exhibits – Requirement to read and explain exhibits to accused – Failure to do so requires expungement; sufficiency of oral evidence and expert identification; appellate jurisdiction to entertain new factual grounds of appeal.
17 September 2021
Defective charge omitting essential elements vitiates trial; conviction quashed for failure to fairly inform the accused.
* Criminal procedure – Particulars of charge – omission of essential elements (other assailants; person subjected to violence) – requirement to inform accused of nature of offence – sections 132, 135(a)(i) CPA. * Curability of defects – limits of section 388(1) CPA and overriding objective – incurable omissions that occasion failure of justice. * Evidence – identification and credibility – delayed identification and contradictory witnesses undermine proof beyond reasonable doubt. * Appeals – second appeal jurisdiction to re‑examine facts where there are misdirections/non‑directions on evidence.
17 September 2021
Procedural irregularities and weak identification evidence led the Court to quash conviction and order release.
Criminal procedure – non-involvement of accused in assessor selection and inadequate summing up – breach of sections 265 and 298(1) CPA; admissibility of witnesses not disclosed at committal – breach of section 289 CPA and expunction of evidence; reliability of visual identification; retrial principles (Fatehali Manji) – retrial not ordered where prosecution case patently weak.
17 September 2021
Failure to comply with assessor procedure and unreliable moonlight identification rendered the trial a nullity; convictions quashed.
Criminal procedure — Participation of assessors — Selection after plea, informing assessors of roles, and giving accused opportunity to object — Failure renders trial a nullity; Evidence — Visual identification at night by moonlight — intensity/conditions must be described and all possibilities of mistaken identity eliminated before reliance.
17 September 2021
Court upheld rape conviction: PF3 by nurse expunged, nurse’s oral observations admissible as lay evidence, appeal dismissed.
Criminal law – Rape of a child – proof of penetration – victim’s testimony and eyewitness corroboration; Evidence – competency of child witness – proper voir dire; Evidence – medical report prepared by a nurse (not a medical practitioner) expunged; Oral observations by a nurse admissible as lay evidence, not expert opinion; Appellate procedure – new grounds not raised in lower court not entertained.
17 September 2021
Failure to read admitted documentary exhibits and inadequate expert identification rendered the prosecution's case insufficient.
Criminal law – unlawful possession of government trophies – admissibility and necessity to read admitted documentary exhibits to accused – expungement where not read – sufficiency of oral expert evidence (game warden) to identify and value trophies – new grounds of appeal in second appeal not permissible.
17 September 2021
Unauthorised alteration of a charge sheet renders it incurably defective; conviction quashed and appellant acquitted.
* Criminal procedure – Amendment of charge – section 234(1) & (2)(a) CPA – court order required before altering a charge sheet. * Criminal procedure – Form of charge – section 135(a)(ii) CPA – statement of offence must describe offence and refer to statutory section. * Appeals – Court of Appeal lacks jurisdiction to consider factual grounds not raised and decided in first appellate court. * Defective charge – unauthorised handwritten alterations render charge incurably defective; cannot be cured under section 388 CPA. * Remedy – conviction and sentence quashed; proceedings nullified; acquittal and immediate release ordered.
17 September 2021
Conviction overturned where overheard statements and an improperly admitted delayed cautioned statement provided insufficient evidence.
* Criminal procedure – admissibility of cautioned statement – section 50 CPA – four-hour rule and section 50(2) exception – requirement for trial-within-a-trial to determine whether statement was made and made voluntarily. * Evidence – confession and admission – hearsay/eavesdropped statements by observers outside a room do not amount to confession unless properly elicited and attributed. * Identification – visual identification under unfavourable conditions (peeping through window, moving celebrants, limited light) unreliable. * Criminal appeal – trial judge reliance on extraneous matters not in evidence – misapprehension of record. * Conviction safety – insufficient evidence warrants quashing conviction and sentence.
17 September 2021
Familiarity-based night identification plus recent possession of stolen motorcycle upheld conviction and 30-year sentence.
* Criminal law – Identification evidence – visual recognition at night where victim and accused were familiar; factors for reliability (proximity, lighting, duration, naming/pointing). * Criminal law – Recent possession – requirements for presumption of guilt where recovered property is positively identified and constitutes the subject of the charge. * Evidentiary burden – accused must rebut presumption by credible, corroborated explanation and produce witnesses/documents to support purchase claim.
17 September 2021
Night-time identification was unsafe; convictions quashed and death sentences set aside due to unreliable eyewitness evidence.
Criminal law – Visual identification at night – reliability and safeguards; extraneous facts in judgment – misapprehension v. incurable irregularity; last-seen doctrine – applicability only where identity established; proof beyond reasonable doubt required.
16 September 2021
April 2021
An application to set aside a CMA ex‑parte award filed after the 14‑day limit is time‑barred, rendering subsequent proceedings nullities.
Labour law — arbitration awards — Rule 30(1) GN No. 64 of 2007 (14‑day limit) — time‑bar and jurisdiction — ex‑parte award — competency to set aside — scope of revision — courts bound by pleadings — revisional powers under s.4(2) AJA.
30 April 2021
A contract claim founded on a 2007 sale was time‑barred; High Court lacked jurisdiction, so its judgment was quashed.
Limitation law — contract claims — accrual of cause of action tied to pleadings; six‑year limitation under Limitation Act item 7 Part I; jurisdiction — time‑barred suits; parties bound by pleadings; functus officio and improper re‑opening of overruled preliminary objections.
20 April 2021
March 2021
Unsubstantiated ill health and age do not constitute exceptional circumstances for bail pending appeal.
Bail pending appeal; Rule 11(2) Tanzania Court of Appeal Rules; onus on convicted appellant to show exceptional/unusual circumstances; ill health and advanced age require current medical evidence; absence of prison officers' affidavit undermines health claims; need to attend other proceedings not necessarily exceptional; court avoids prejudicial assessment of appeal prospects.
31 March 2021
Applicant failed to prove exceptional circumstances (age, ill-health, pending trial) to justify bail pending appeal.
Criminal procedure – Bail pending appeal – Onus on convicted appellant to show exceptional or unusual circumstances; old age/ill-health require substantiation by current medical evidence; need to attend another trial not ordinarily exceptional; court generally refrains from assessing appeal merits at bail stage.
31 March 2021
Appeal struck out as time-barred due to appellants' failure to apply for and serve request for court records.
Civil procedure – Appeals – Time limitation under Rule 90(1) Court of Appeal Rules 2009; requirement to apply in writing for copies of proceedings within 30 days and to serve the application on respondent (Rule 90(3)); validity of certificate of delay dependent on existence and service of application; jurisdictional effect of non-compliance with mandatory time rules; overriding objective cannot cure jurisdictional time-bar.
31 March 2021
Conviction based on weak circumstantial proof and a flawed identification parade was unsafe and quashed.
Criminal law – Unnatural offence (sodomy of a child) – proof of penetration by medical and immediate witness evidence; Circumstantial evidence – requirement of a complete chain pointing irresistibly to the accused; Identification evidence – identification parade must follow procedures and similar appearance of participants; Admissibility of exhibits distinct from weight to be accorded; Doubts to benefit the accused – unsafe conviction to be quashed.
17 March 2021
A judgment not pronounced in open court with notice is invalid; appeal struck out and matter remitted for fresh judgment.
Civil procedure – Order XX Rule 1 CPC – Pronouncement of judgment in open court – Notice to parties – Validity of judgment and decree – Inoperative judgment cannot be appealed – Remedy: quash and remit for fresh judgment by different judge.
8 March 2021
Conviction for child rape upheld but life sentence reduced to thirty years due to insufficient proof the victim was under ten.
* Criminal appeal — second appeal jurisdiction — court will not determine new factual grounds not raised in first appellate court. * Evidence — child witness — voir dire examination required under s.127 Evidence Act (as then in force) to assess competence. * Evidence evaluation — trial court must analyse prosecution and defence evidence; sufficient analysis here. * Proof of age — required to justify life sentence for rape of girl under ten; uncertainty benefits accused — revisional reduction of sentence.
2 March 2021
Irregular psychiatric report admission harmless; post‑mortem expunged but eyewitnesses proved murder — appeal dismissed.
Criminal law – murder – admissibility of medical and post‑mortem reports – compliance with s220 CPA for psychiatric reports; cumulative requirements of s34B Evidence Act for witness statements; failure to read exhibits aloud; expungement of improperly admitted documents; proof of cause of death by eyewitness and circumstantial evidence; malice aforethought and self‑induced intoxication not a defence.
2 March 2021